Sanctions screening
Sanctions screening in the Technology, AI and Competition sector is no longer a peripheral compliance function. The U.S. Department of the Treasury's Office of Foreign Assets Control and the U.S. Department of Commerce Bureau of Industry and Security have both tightened controls on technology transfers, AI model exports, and semiconductor-adjacent software in the past two years, with BIS's October 2023 advanced computing rule expanding the entity list review burden for any firm with cross-border AI infrastructure. Compliance teams at technology companies are now mapping cloud service agreements, GPU procurement chains, and AI partnership arrangements against OFAC's SDN list and BIS export control classifications before contracts close.
Watch
- BIS Entity List additions targeting AI chip suppliers and frontier model developers
- OFAC guidance on virtual asset sanctions exposure for technology payment rails
- Whether the EU's dual-use export control reform touches AI model weights
- New SDN designations naming technology firms with ties to sanctioned jurisdictions
Recent material activity in Technology, AI & Competition
Active monitoring in place across Technology, AI & Competition. Material developments related to sanctions screening will appear here as they are published.